I signed on to a program that was to form student investor groups in various cities that would offer extensive training at no cost AND 100% funding of flip deals up to 70% of ARV to the students in exchange for a specific term of 50/50 profit splitting between each of the program directors and their respective students. Before most of the students were ready to do their first deals, the 100% funding was abruptly taken off the table leaving the students with the grim reality and necessity of making down payments of 20% on their deals - something they were not prepared to do and which they had been specifically told they would not have to do. After recovering from the punch to the gut, I began to think about how to keep the endeavor viable according to the original plan of financing deals. I would like to know how to legally attract and form a replacement group of lenders - either as a pool who collectively lend on each deal, or a group of individual lenders to which deals will be submitted on an individual basis according to the terms offered to the student investors. Aside from the obvious presentation of the enterprise and evidence of strong deals with solid numbers, how can this be done without taking on the appearance of a security offering, and where and how would I begin to look for participants ? I am one of the program directors, and I could just walk away from the whole thing and lick my wounds, but aside from needing to move ahead for my own financial benefit, I feel responsible to the the people I recruited based on the original template I was given, and I don't want to see them robbed of their hopes and aspirations.